News & Analysis as of

Bank Deposits Financial Institutions

Orrick, Herrington & Sutcliffe LLP

FDIC solicits a request for information on deposit data

On July 30, the FDIC released an RFI for deposit data, specifically data not reported in the Federal Financial Institutions Examination Council’s (FFIEC) call reports or other regulatory reports. The FDIC is seeking comments...more

Troutman Pepper

FDIC Proposal Would Classify More BaaS Deposits as Brokered, Not Core

Troutman Pepper on

“I would say a lot of these fintechs deposits are actually the opposite of hot money,” said Matthew Bornfreund, a partner at Troutman Pepper. “I think a problem with this proposed rulemaking is, the FDIC asserts that these...more

Morrison & Foerster LLP

Banking Agencies Address Banking Arrangements with Third Parties to Provide Deposit Products and Services

On July 25, 2024, the Federal Reserve Board, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (collectively, the “Agencies”) issued a joint statement to banks regarding risks...more

Goodwin

FDIC Proposes Overhaul to Brokered Deposit Classification Rules; Significant Impact to Banking as a Service (BaaS) Industry

Goodwin on

On July 30, 2024, the Federal Deposit Insurance Corporation (FDIC) issued a proposed rule that would make significant revisions to the FDIC’s regulations implementing the provisions of Section 29 of the Federal Deposit...more

Orrick, Herrington & Sutcliffe LLP

Washington State enshrines new act on uniform special deposits

On March 13, the Governor of Washington State signed into law SB 5801, enshrining a new chapter titled the Uniform Special Deposits Act. The law will apply to special deposits under account agreements that intend to establish...more

GeoDataVision

Reg. CC-Funds Availability, it ’s a good time to revisit the hold provisions and timing for Reg. CC.

GeoDataVision on

In episode 64 of the Compliance 911 podcast, hosts Len Suzio and Dean Stockford discuss the intricacies of Reg. CC, a regulation that deals with funds availability. Dean emphasizes the importance of understanding the...more

Cadwalader, Wickersham & Taft LLP

The Other Green Scene: Sublines for Evergreen Funds June 2023 - When Deposits Don’t Travel with Loans

In a March 16 hearing before the U.S. Senate Finance Committee, Treasury Secretary Janet Yellen explained that uninsured deposits would be guaranteed only following a determination that “the failure to protect uninsured...more

Spilman Thomas & Battle, PLLC

Promissory Notes - Banking & Finance Insights: V 3, Issue 3, March 2023

Now is the Time to Guard Against Reckless Banking Legislation - “Only a structural change to the way Congress acts on financial regulation will prevent future losses.” Why this is important: An old adage is that...more

Fox Rothschild LLP

The Extraordinary Silicon Valley Bank Collapse: What We Know

Fox Rothschild LLP on

On Friday morning, regulators closed Silicon Valley Bank (SVB), roiling the startup world and creating uncertainty about the availability of deposits and the availability of credit to its customers and borrowers. Unexpected...more

Porter Hedges LLP

Texas Supreme Court Highlights Two Key Takeaways for Texas Banks about Contractual Liability for Email Wire Transfer Scams

Porter Hedges LLP on

To avoid contractual liability for their customer’s wire fraud losses caused by phishing email scams, banks should understand two things from the Texas Supreme Court’s recent opinion in Cadence Bank, N.A. v. Elizondo: (1)...more

Farella Braun + Martel LLP

Tips For Banks As USAA Check Deposit Patent Dispute Grows

In January 2020, we wrote a Law360 guest article that highlighted some of the risks that followed Wells Fargo Bank NA's strategy in its patent dispute with the United Services Automobile Association over remote deposit check...more

Farella Braun + Martel LLP

Strategy Lessons From Wells Fargo Fintech Patent Litigation

United States Automobile Association (USAA) is a financial services company that provides insurance, banking, investment, and retirement products and services for members of the military and their families. On June 7, 2018,...more

Stinson LLP

Mobile Check Deposit Patent Case Headed for Trial

Stinson LLP on

Companies involved in mobile checking should watch case closely - The United States Automobile Association (USAA) owns a portfolio of patents aimed at mobile check deposit technology. One group of these patents is targeted...more

Hudson Cook, LLP

Current Developments in Bank Deposits and Payment Systems (Spring 2019)

Hudson Cook, LLP on

This survey summarizes several recent developments affecting bank deposits and payment systems. The U.S. department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued new guidance concerning the customer...more

A&O Shearman

UK Financial Conduct Authority To Allow 90-Day Unbreakable Deposits For Client Money

A&O Shearman on

The UK Financial Conduct Authority has published a Policy Statement and final rules to introduce changes to its client money rules to amend the existing 30-Day Rule, under which firms are prevented from placing client money...more

K&L Gates LLP

Regulation CC Amendments Reallocate Risks of Remote Deposit

K&L Gates LLP on

More than three years after proposing amendments to Regulation CC to add new indemnities for remotely deposited checks, new warranties for electronic checks and electronic returned checks, and new indemnities for...more

Orrick - Finance 20/20

European Commission to Publish Legislative Proposal on Common Deposit Guarantee System by End of 2015

Orrick - Finance 20/20 on

Jean-Claude Juncker, President of the European Commission, has announced that the Commission will publish a legislative proposal on first steps towards establishing a common deposit guarantee system by the end of 2015. His...more

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